DEPARTMENT OF THE ARMY HEADQUARTERS, US ARMY GARRISON, FT RUCKER FORT RUCKER, ALABAMA Fort Rucker Regulation 22 December 2014 No.

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1 DEPARTMENT OF THE ARMY HEADQUARTERS, US ARMY GARRISON, FT RUCKER FORT RUCKER, ALABAMA *Fort Rucker Reg Fort Rucker Regulation 22 December 2014 No Inventory Management HAZARDOUS MATERIAL MANAGEMENT PROGRAM (HMMP) 1. PURPOSE. This regulation establishes a centralized HMMP and responsibilities for the management of hazardous material (HM) and hazardous waste (HW) within Fort Rucker. The core objective is to improve logistics and operational mission performance by controlling and reducing the acquisition, use, handling, and disposal of HM and the generation of HW, consistent with Army supply chain integration and sustainability objectives. 2. REFERENCES. a. Army Regulation (AR) 200-1, Environmental Protection and Enhancement, 13 December b. AR 710-2, Supply Policy Below the National Level, 28 March c. Department of the Army (DA) Pamphlet 710-7, Hazardous Material Management Program, 25 June APPLICABILITY. This program is applicable to all Fort Rucker activities, tenants, and personnel. 4. PROPONENT. The proponent of this program is the Fort Rucker Logistics Readiness Center (LRC). Recommendations are welcome and should be forwarded to the Chief, Supply and Services Division, in written format. Recommended enhancements should include the submitting activity; point of contact name, address, and telephone number; specific section to be enhanced; proposed enhancement; new text, and justification, to include benefits and drawbacks. 5. MISSION STATEMENT. The Fort Rucker HMMP is an initiative to enhance readiness and improve sustainability through controlling and tracking the acquisition, use, handling, and disposition of HM. The program serves as the base focal point for HM and HW management. It combines many of the traditional functions of the Environmental and Natural Resources Division, Supply, Contracting, Logistics, and Installation Safety Office (ISO). The Fort Rucker HMMP establishes an organization and business practices to implement centralized HM management throughout the Garrison. 6. FUNDAMENTAL PURPOSE. The fundamental purpose of the Fort Rucker HMMP is to minimize, track, and control the ordering, storing, distribution, use, and disposition of HM through the effective use of single point control. It also facilitates the tracking of HW from generation to final disposal. Essential to the program is the requirement to obtain and maintain updated copies of manufacturers material safety data sheets (MSDSs) or safety data sheets (SDSs) for all HM brought *This regulation supersedes Fort Rucker Reg 710-3, 17 Jun 11. 1

2 on Fort Rucker. The program utilizes standard Army supply management systems and a Hazardous Material Management System/Enterprise Environmental, Safety, and Occupational Health Management Information System (HMMS/EESOH-MIS) to facilitate necessary tracking and provide a centralized database for management and compliance reporting. The HMMS/EESOH-MIS links processes to materials used and wastes generated. It tracks materials and chemical constituents throughout their life cycle on Fort Rucker and facilitates potential health hazard and exposure tracking. The HMMS/EESOH-MIS also prepares key mandatory environmental reports and facilitates management reporting. 7. DUTIES. a. The Garrison Commander will (1) Ensure that integrated logistics, environmental, occupational safety and health, and hazardous substance (HS) policy and procedures are established and disseminated installation-wide. (2) Appoint the following: (a) oversight. (b) An Environmental Quality Control Committee (EQCC) for environmental quality An HMMP Working Group for day-to-day operational oversight. (c) The Chair of the HMMP Working Group. The voting membership of the working group is made up of delegates from the command and staff organizations that comprise the EQCC, with each organization having a single voting member. 2 b. The Chair of the HMMP Working Group will (1) Ensure Fort Rucker compliance with applicable environmental guidance and procedures. (2) Obtain necessary resources to maintain the HMMP. c. The Director, LRC, will (1) Designate a representative to serve as deputy to the Chair and as a voting member of the Fort Rucker HMMP Working Group, who schedules committee meetings, publishes agendas, and prepares reports for the Garrison Commander. (2) Establish a Hazardous Material Control Center (HMCC) to provide centralized acquisition, storage, issue, and tracking of HM throughout its life cycle on Fort Rucker. (3) Publish a standing operating procedure (SOP) for HMCC operations and customer support. (4) Ensure that HMCC personnel and other HMMS/EESOH-MIS users receive proper HM management software training. (5) Ensure the safe receipt, handling, storage, and issue of HM.

3 (6) Ensure that MSDSs/SDSs are readily available and issued with HM to assure proper handling and emergency response preparedness. (7) Ensure that the processing of unit or activity turn-ins is timely in order to maximize the potential for transfer and/or reutilization of HM prior to shelf life expiration. (8) Provide necessary logistics data to the Garrison staff in support of Environmental HMMP reporting requirements. (9) Conduct scheduled and unscheduled HMMP assessments, to include site inspections and assistance visits. The mission will not be impacted by any scheduled or unscheduled HMMP assessment. d. The Chief, Environmental and Natural Resources Division, Directorate of Public Works (DPW), will (2) Provide HS environmental input to the Garrison Commander and HMMP Working Group. (3) Coordinate with LRC to ensure that environmental requirements are integrated into the Fort Rucker HMMP. (4) Recommend HMMP goals and objectives, consistent with higher headquarters guidance, and conduct annual pollution prevention assessments to identify opportunities for enhancing pollution prevention efforts and to measure goal achievement. (5) Administer the Fort Rucker HM management information tracking system and collect data to meet compliance and management reporting requirements. (6) Provide environmental staff oversight, guidance, and inspection of Fort Rucker and tenant activity operations, sometimes in conjunction with the safety and/or external offices. (7) Identify potential nonhazardous product substitution. to (8) Coordinate with LRC, ISO, and the Lyster Army Health Clinic Industrial Hygiene Office (a) Ensure that HS spill response is immediate and in accordance with (IAW) the site spill response plan. Notify the Environmental and Natural Resources Division, DPW; Fire Department, and ISO when appropriate. (b) Identify processes that use HM, generate HW, or result in unsafe conditions for personnel on Fort Rucker. (c) (d) (e) Identify HM, authorized users, and levels of storage per location. Preauthorize HM prior to first-time ordering. Maintain and process updates of MSDS/SDS data. 3

4 (f) Provide MSDS/SDS information to the Fire Department. (9) Review and approve authorized use list (AUL) change requests in coordination with ISO. (10) Establish and operate an HW Management Office to provide collection, disposal, and recycling of HM and wastes. (11) Prepare ad hoc HS management reports, as required. (12) Determine and track necessary HS training for Fort Rucker personnel. e. The Director, ISO, will (2) Provide safety input to the Garrison Commander and HMMP Working Group. (3) Conduct occupational safety and health planning for Fort Rucker. (4) Coordinate with the Environmental and Natural Resources Division, DPW, to establish policy and procedures to (a) (b) (c) Identify HM and authorized users. Preauthorize HM prior to first-time ordering. Provide MSDS/SDS information to the Fire Department. (5) Conduct occupational safety and health assessments to identify opportunities for enhancing safety efforts and reducing risks to Fort Rucker personnel. 4 (6) Participate in AUL change approvals. (7) Include identification of HM not in the HMMS/EESOH-MIS database during activity assistance visits and report these items to the HMCC Manager for appropriate action. (8) Conduct hazard communication training for Fort Rucker personnel. f. The Chief, Business Operations Division, DPW, will (2) Establish procedures to implement Fort Rucker HMMP policy within the Business Operations Division. g. The Lyster Army Health Clinic Logistics Division Supply Officer will (1) Follow Surgeon General guidance and establish a Hazardous Material Control Point (HMCP).

5 (2) Publish an SOP for HMCP operations and customer support. (3) Enter HM procurements and usage into the Medical Command HM software as they occur or at least weekly. h. The Director, Network Enterprise Center (NEC), will (2) Ensure adequate networking to support efficient HMMS/EESOH-MIS transactions between the server and clients, as required. (3) Provide necessary internet protocol addresses and network access to support HMMS/EESOH-MIS operations. New requirements will be accomplished on a reimbursable basis. i. The HMMP Working Group will (1) Be responsible for the integrated efforts necessary to successfully implement HM management software and support enhanced HMMP business practices on Fort Rucker. (2) Develop the implementation plan for the HMMP, assign roles and responsibilities, identify and assign actions with necessary milestones, and ensure that milestones are satisfactorily completed. (3) Serve as the implementation workgroup for the HMMP. (4) Provide oversight of HMMP operations. (5) Conduct periodic in-progress review briefings on the status of HMMP implementation and ongoing operations. (6) Be chaired by the Garrison Commander s designee. (7) Include representation from LRC, DPW, ISO, NEC, and all tenant activities. The Garrison Commander or EQCC adjusts membership, as required. j. The HMMS/EESOH-MIS is the preferred program for managing and tracking HM and waste compliance reporting. The HMMS/EESOH-MIS Database Manager, LRC, will (1) Establish HMMS/EESOH-MIS access rights as directed by the HMMP Working Group. Conduct day-to-day maintenance of the HMMS/EESOH-MIS database and periodic update of tables, as required. (2) Ensure the daily backup of HM management transaction data. (3) Respond to Garrison HM management software functional questions. (4) Coordinate HM management software updates with appropriate offices and the software provider. 5

6 6 (5) Receive and track Fort Rucker HM management software engineering change proposals. (6) Assist the Chief, Environmental and Natural Resources Division, DPW, in preparing reports using HM management software data, as required. (7) Support HMCC Material Specialists, HMMS/EESOH-MIS users, and HW Managers in correcting data. (8) Assist NEC in identifying and correcting network problems related to HM management software, as required. k. The HMCC, Supply and Services Division, LRC, will (1) Establish policy on the acquisition and storage of HM IAW Fort Rucker policy. (2) Manage HM as an integral part of the supply mission, maintain an HM inventory consistent with standard Army procedures, and provide a sole source of HM to Fort Rucker activities. (3) Establish and publish operating hours consistent with customer requirements. (4) Publish customer procedures for HM transactions. (5) Establish a requisitioning objective and reorder point for each HM required to be stocked and use just-in-time requisitioning to the extent possible, using the Army Supply System and local purchase procedures. (6) Establish procedures for meeting emergency HM requirements. (7) Establish an HM reuse capability. (8) Ensure that HMCC personnel receive HS handling and management training, to include HMMS/EESOH-MIS transaction training. (9) Ensure that MSDSs/SDSs are maintained for all requisitioned and stored HM and that MSDSs/SDSs accompany received HM. (10) Document all HM transactions using the HMMS/EESOH-MIS. (11) Issue requested HM from the source of supply. (12) Receive empty HM containers from customers and ensure that HM usage has been recorded by customer supply issue point in the HMMS/EESOH-MIS. (13) Participate in the Fort Rucker HMMP Working Group. (14) Ensure that spill plans are prepared, available for emergency response, and reviewed and updated at least annually. (15) Ensure that appropriate spill response materials are on hand.

7 l. The Director of Public Safety will (2) Provide policy and guidance on all fire-related issues as they pertain to HM and HW. m. The Director, Mission and Installation Contracting Command-Fort Rucker, will (2) Set up contract mechanisms with local vendors to meet customer requirements for local purchase items. Delivery will be to the HMCC, Supply and Services Division, LRC, who will then issue the procured HM to the installation customer using the HMMS/EESOH-MIS. (3) Provide guidance controlling the use of government purchase cards (GPCs) for HM procurement. (4) Ensure that all service, maintenance, and construction contracts include statements that facilitate full support of the Fort Rucker HMMP. holders. (5) Report to the Garrison Commander and HMCC the purchase of unauthorized HM by GPC n. Fort Rucker activity chiefs and tenants will (1) Ensure that all processes, HM, and waste streams have been approved and incorporated into the HMMP AUL to allow expeditious HM transactions. (2) Ensure the establishment of 2-week shop/laboratory supply levels for HM normally used in day-to- day business. (3) Ensure that HM in excess of the approved stockage level or known immediate need is returned to the HMCC. This includes open or closed containers of usable materials. (4) Obtain all HM through the appropriate HMCC. (5) Return empty containers or report actual HM usage to the HMCC as coordinated between the HMCC and the customer. (6) Ensure that work areas and laboratories maintain the correct manufacturer s MSDSs/SDSs for each HM used and/or stored. (7) Designate personnel authorized to request, receive, and store HM. (8) Obtain and mark appropriate containers for collecting used HM. (9) Coordinate the turn-in of unserviceable HM with the HW Management Office. (10) Designate personnel authorized to coordinate and turn in HW. 7

8 (11) Ensure that all personnel exposed to HS in the course of their work receive proper training and that proper and adequate personal protective equipment (PPE) is stocked, maintained, and issued to personnel. (12) Coordinate environmental and safety training with the Environmental and Natural Resources Division, DPW, and ISO. Ensure that all personnel are made aware of and comply with this program. 8 (13) Provide representation to the Fort Rucker HMMP Working Group. (14) Inspect work areas to ensure that HM has been recorded in the HMMS/EESOH-MIS, HM is properly rotated and stored, and used HM is properly marked IAW Fort Rucker and activity guidance. (15) Ensure that spill plans are prepared, approved, available for emergency response, and reviewed and updated at least annually. (16) Ensure that appropriate spill response materials, for minor spills only, are on hand. o. Individual personnel handling and using HS will (1) Seek appropriate training when tasks include the handling of HS. (2) Ensure that MSDSs/SDSs are on hand (in electronic or hard copy) for all HM used or on hand. Be familiar with potential hazards associated with each HM used or on hand. (3) Wear appropriate PPE when handling HS. Refer to the MSDSs/SDSs, product labels, technical manuals, and/or ISO for guidance. Individuals should also ensure that PPE is maintained IAW applicable technical documents. (4) Handle HM IAW the MSDS/SDS and product labels. (5) Store HM IAW Army and Fort Rucker guidance and approved procedures. (6) Place used HM in properly marked containers. (7) Notify supervisors and section chiefs (when appropriate) when new processes or materials are required and/or new waste streams will be generated. (8) Contain all spills immediately and report them to supervisors. For spills that are too large or those that pose a safety or health threat to personnel or the environment, immediately notify the Fire Department and the Environmental and Natural Resources Division, DPW. Consult individual activity spill plans for more details. 8. AUL (HM, PROCESSES, AND ALGORITHMS). a. AUL Definition. (1) The AUL is the listing of processes and materials approved for use within Fort Rucker activities and tenants.

9 (2) The AUL is the composite of the HMMS/EESOH-MIS table information that links processes using HM and/or generating HW, authorized HM, anticipated waste streams, and algorithms to estimate releases. An HMMS/EESOH-MIS AUL record is created when an HMMS/EESOH-MIS master inventory record is approved for use or storage on Fort Rucker and is linked to a site-specific process record. (3) Each authorization includes a review and approval of all aspects of a process, the HM used, the process using the HM, the resulting waste stream(s) and emissions, and the work center(s) involved. The AUL supports DA and Fort Rucker HMMP policy and can be used for International Organization for Standardization efforts. b. AUL Use. (1) The AUL is used to control HM acquisition, to identify types of HM usage, to estimate HW generation, to prepare environmental reporting, and to prevent pollution. Each requisition, receipt, and issue transaction is validated against the AUL prior to completion. The Environmental and Natural Resources Division, DPW, will report all transaction exceptions to the AUL to LRC for appropriate action. The HMMS/EESOH-MIS automatically validates each issue transaction against established authorizations prior to issue. Unauthorized requests cause a system warning, which must be overridden by the HMCC Operator. Overriding the warning requires approval from the Environmental and Natural Resources Division, DPW. Overriding the AUL and shelf life expiration message during material transactions creates exception reports. Work area supervisors, the Environmental and Natural Resources Division, DPW, and ISO review exception reports and take actions necessary to correct the cause for the current exception and those actions needed to preclude a recurrence. (2) Each distinct operation, such as painting, using a recirculating solvent parts washer, performing a medical procedure, or conducting research protocols, constitutes a process in the HMMS/EESOH-MIS. Processes can be activity-specific but are generally not location-specific. Processes generate waste. (3) HW characterization records describe the waste and waste container. HW characterizations can be referenced using unique names, locally assigned codes, or contract line numbers. An algorithm for each approved process is created and entered into the HMMS/EESOH-MIS. Algorithms predict the fate of materials used in a process and use this to collect information for the Emergency Planning and Community Right-to-Know Act (EPCRA) Form R Report and for pollution prevention opportunity assessments. The Environmental and Natural Resources Division, DPW, establishes HMMS/EESOH-MIS process algorithms. c. Maintaining the AUL. (1) All supervisors are responsible for ensuring that the HMMS/EESOH-MIS database accurately reflects approved processes, HM used, and HW generated. AUL change requests are processed through the Environmental and Natural Resources Division, DPW. Changes to HM usage are processed in advance of HM procurement to ensure the efficient flow of HM through the HMCC. (2) Proper HM management requires pollution prevention opportunity assessments and reporting. 9

10 (3) HMMP inspection points will be added to the command logistics inspection criteria by LRC. The Environmental and Natural Resources Division, DPW, will conduct inspections and assistance visits on a scheduled and unscheduled basis to the HMCC to verify that HMMP policy and guidance has been implemented and is being followed. Inspection results will be provided to the Chief, Supply and Services Division, LRC, for corrective action. A copy of the report identifying shortcomings, opportunities for improvement, and recommended solutions is forwarded to the HMMP Working Group for review and appropriate action. (4) The Environmental and Natural Resources Division, DPW, conducts pollution prevention opportunity assessments, which identify the potential for reduced HM acquisition through changes to processes or material substitution. They also assist in identifying opportunities to reduce HW generation through material substitution or process change. The HMMS/EESOH-MIS provides sufficient HW, HM, and chemical inventory and uses information to support assessments. The HMMS/EESOH-MIS also provides the capability to automate EPCRA reporting and biannual HW reporting. The centralized database provides opportunities for ad hoc management reporting. (5) Fort Rucker activities are encouraged to take advantage of this management tool. Requests are made through the Environmental and Natural Resources Division, DPW. Inspection reports are provided to operational managers and to the HMMP Working Group for appropriate action. (6) ISO will add HMMP criteria to annual and periodic inspections and assistance visits. Criteria will include identification of on-hand HM that is not approved for a process, processes with no associated and approved material, lack of required or maintained PPE, and status of training for HM use. Inspection reports will be provided to operational managers and to the HMMP Working Group for appropriate action. d. Expected HMMP Benefits. The Fort Rucker HMMP (1) Helps the Garrison Commander protect human health and the environment through enhanced compliance with existing laws and regulations. This further supports sustainability objectives. (2) Can generate savings through the reduction of usage, elimination of duplicate tracking and information systems, control of ozone depleting substance (ODS) waiver allocations, and support of the new tasks imposed on all Garrisons by Executive Order 13423, Strengthening Federal Environmental, Energy, and Transportation Management. (3) Contributes to the safe handling of ODS and HM and reduces the potential for notices of violations and the monetary fines associated with them. (4) Eliminates duplicative HM tracking and reporting functions and provides data showing the status and location of HM to all post organizations requiring that information. (5) Can realize cost savings in both the procurement of HM and the disposal of hazardous and solid wastes. (6) Addresses inherent problems with shelf life expiration dates, environmental and occupational safety and health risks, safe storage requirements, security, disposal and liability costs, and tracking and reporting requirements. 10

11 (7) Can realize significant cost savings from reducing the amount of HM. The proponent agency of this regulation is the Supply and Services Division, Logistics Readiness Center. Users are invited to send comments and suggested improvements to the US Army Garrison Command, ATTN: ASCE-LRU, Fort Rucker, AL FOR THE GARRISON COMMANDER: DEBORAH L. SEIMER Director of Human Resources 11